by Gavel Law | Feb 26, 2025 | Gavel Law, Private Wealth, Tax Avoidance, Taxation Law, Trusts
The Commissioner of Taxation (Commissioner) has had a long-standing view that an unpaid present entitlement (UPE) by a trust to a corporate beneficiary is a form of “financial accommodation” where the beneficiary can (but does not) demand the entitlement. This meant...
by Gavel Law | Apr 5, 2024 | Gavel Law, Property Law, Tax Avoidance, Taxation Law
The Full Federal Court decision The Full Federal Court decision of Minerva Financial Group Pty Ltd v Commissioner of Taxation [2024] FCAFC] 28 decided that Part IVA of the Income Tax Assessment Act 1936 did not apply to a trustee’s failure to exercise its...
